Doe v. Noem
2:25-cv-01103
E.D. Cal.Jun 16, 2025Background
- The defendants filed a renewed request to seal and redact documents relating to a stipulation for dismissal in a case involving a plaintiff identified as Student Doe.
- Defendants sought to file both a redacted copy of the stipulation (for public record) and an unredacted copy under seal (for the court only).
- The central concern was information that could identify the plaintiff, whose confidentiality had previously been recognized by the court as a compelling reason for sealing.
- The court had previously denied a broader sealing request for not being narrowly tailored but indicated that some sealing could be justified.
- The renewed request proposed redacting only the plaintiff’s identifying information, with all other material being filed publicly.
- The court found this approach to be appropriately limited to protecting confidential material and granted the renewed request.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stipulation for dismissal should be filed under seal or with redactions to protect plaintiff’s identity | Not specified in order | Plaintiff’s identity must be protected; redaction of identifying info is sufficient | Narrow redaction and sealing of identifying information is granted |
| Applicable legal standard for sealing dispositive documents | Not specified | "Compelling reasons" standard applies because of the dispositive nature of stipulation | Compelling reasons standard applies |
| Scope of redactions needed to protect confidential information | Not specified | Only info that identifies plaintiff should be sealed; rest can be public | Only plaintiff's identifying info sealed, rest unsealed |
| Compliance with prior court orders regarding sealing | Not specified | Current request is narrowly tailored per prior court guidance | Request is compliant, so motion granted |
Key Cases Cited
- San Jose Mercury News, Inc. v. U.S. Dist. Ct., 187 F.3d 1096 (9th Cir. 1999) (explaining the presumption of public access to court records and filings)
- Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (distinguishing the “compelling reasons” and “good cause” standards for sealing court records)
- Pintos v. Pac. Creditors Ass’n, 605 F.3d 665 (9th Cir. 2010) (outlining standards for sealing documents based on whether they are attached to dispositive or non-dispositive motions)
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (general right of public access to judicial records; exceptions for compelling reasons)
- Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122 (9th Cir. 2003) (application of differing standards for sealing dispositive vs. non-dispositive filings)
- Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092 (9th Cir. 2016) (compelling reasons standard applies to motions more than tangentially related to the merits)